Finding 508409 (2023-004)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-11-20

AI Summary

  • Core Issue: The Authority failed to verify that a consultant was not debarred or suspended before awarding contracts for the Certified Community Behavioral Health Clinic Expansion Grant.
  • Impacted Requirements: Compliance with federal regulations requiring checks for debarment and suspension (2 CFR sections 200.212 and 200.318(h)).
  • Recommended Follow-up: Implement controls to ensure verification of debarment and suspension occurs prior to entering into any covered transactions.

Finding Text

2023-004: Evaluating Potential Contractor for Debarment and Suspension Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086680-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CRF section 180.300; 48 CFR section 52.209-6). Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Authority did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred for two of the three contracts expended. The Authority checked suspension and debarment on the individual clinicians, however, did not check it for the company. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None. Subsequently, the sam.gov was reviewed to ensure that the contractors were not suspended or debarred. Context: The consultant utilized for the Certified Community Behavior Health Clinic Expansion Grant project were not evaluated prior to the award of the contract. Cause/Effect: The Authority did not have controls in place to ensure timely compliance with the suspension and debarment evaluation requirements prior to the awarding of contracts for the Certified Community Behavioral Health Clinic Expansion Grant or other federal funds. Recommendation: We recommend the Authority implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering covered transactions. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.

Corrective Action Plan

Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Authority did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred for two of the three contracts expended. The Authority checked suspension and debarment on the individual clinicians, however, did not check it for the company. Recommendation: The Authority should implement adequate controls to ensure verification of debarment, suspension or exclusion takes place before entering covered transactions. Planned Corrective Action: Going forward the agency will implement policy changes that will include the organization as well as the individual prior to entering into any contract. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 508406 2023-001
    Material Weakness
  • 508407 2023-002
    Material Weakness
  • 508408 2023-003
    Material Weakness
  • 508410 2023-005
    Material Weakness
  • 508411 2023-006
    Material Weakness
  • 1084848 2023-001
    Material Weakness
  • 1084849 2023-002
    Material Weakness
  • 1084850 2023-003
    Material Weakness
  • 1084851 2023-004
    Material Weakness
  • 1084852 2023-005
    Material Weakness
  • 1084853 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.696 Certified Community Behavioral Health Clinic Expansion Grants $568,350
93.778 Medical Assistance Program $26,610
93.958 Block Grants for Community Mental Health Services $5,814